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of <h1>Profits from international shipping or aircraft operations are taxable only in the enterprise's home state per agreement rules.</h1> Profits from the operation of ships or aircraft in international traffic by an enterprise from a Contracting State are taxable only in that State. If a shipping enterprise's management is aboard a ship, it is considered located in the State where the ship's home harbor is, or where the operator resides if no home harbor exists. Profits from using, maintaining, or renting containers for international transport by a resident enterprise are taxable only in that State, unless used solely within the other State. These rules also apply to profits from participation in pools, joint businesses, or international operating agencies.
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